Date: November 6
, 201 4

To: Jeff Telander, EPA /OAQPS/SPPD

From: Gabrielle Raymond
, RTI International

Subject: Test Data Used in BSCP Proposed Rule

I. Introduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) established national emission standards for hazardous air pollutants (NESHAP) on May 16, 2003
, for the brick and structural clay products (BSCP) manufacturing industry. The NESHAP regulated emissions of hydrogen fluoride (HF)
, hydrogen chloride (HCl), and particulate matter (PM)

— a surrogate for hazardous air pollutant (HAP) metals

— from tunnel kilns located at BSCP facilities

. O n March 13, 2007 , t he D.C. Circuit Court vacated the emission standards for BSCP manufacturing due to issues associated with the methodology used to determine the minimum regulatory “floors” for new and existing units

. 1 Therefore
, the EPA is propo sing new standards for BSCP manufacturing
, includ ing limits for HF, HCl, chlorine (Cl 2 ), mercury (Hg), and non

- Hg metals (or PM surrogate)

. Th e purpose of th is memo randum is to describe the sources of test data obtained for BSCP tunnel kilns and dryers and considered in the BSCP ru lemaking and to describe the quality assurance/quality control ( QA / QC ) checks performed o n the data

.
II. Sources of Data

The main sources of test data were responses to the 2008 and 2010 section 114 surveys to the BSCP industry (described in the remainder of this section)
, test data in the BSCP Legacy Docket A

- 99

- 30, and test reports that the Brick Industry Association (BIA) sent to the EPA to provide test data for facilities not covered by the section 114 surveys

. Copies of al l the test reports collected from these sources are included in Docket ID No. EPA

- HQ

- OAR

- 2013

- 0291

. The EPA conducted two surveys under the authority of section 114 of the CAA. In June 2008
, the EPA se n t out a survey to nine BSCP companies

— Acme Brick, The Belden Brick Co., Boral Bricks, Inc., Carolina Ceramics Brick Co., General Shale Brick, Inc., Glen

- Gery Corp., Hanson Building Products America, Morin Brick Co., and Taylor Clay Products, Inc. ( Tsirigotis
, 2008)

. The survey was designed in the form of a Microsoft Excel ® spreadsheet file that

1 Sierra Club v. EPA , 479 F.3d 875 (D.C. Cir. 2007).2 included seven different worksheets to complete

. The main intention of the survey w as to collect inventory information about the kilns at those nine companies. Although the 2008 survey did not require any new testing to be performed, t he “ Form D

- Test Data ” worksheet in the survey asked for information on emission tests previously performed on kilns at the facilities and asked each facility to submit complete copies of the reports for these emission test s

. T he t est re ports received contained results for HF, HCl, Cl 2 , and filterable PM.

In 2010
, the EPA sent out another section 114 survey to nine BSCP companies

. The survey was sent out in two phases. Phase I of the survey was sent out to three compan ies ( The Belden Brick Co., Boral Bricks, Inc. , and Hanson Building Products America ) and required testing of HF, HCl, Cl 2 , PM filterable , HAP metals including Hg , and d ioxin / f uran emissions from tunnel kilns and testing of d ioxin / f uran emissions from dryers ( Ts irigotis , 2010a

- c)

. Phase II of the survey was sent out to six companies (Acme Brick, General Shale Brick, Inc., Glen

Gery Corp., Interstate Brick, Jenkins Brick and Tile Company, and Taylor Clay Products, Inc.) and required testing of HF, HCl, C l 2 , PM fil terable , and HAP metals emissions from tunnel kilns (Tsirigotis, 2010 d

- i)

. Instead of performing new stack tests, Interstate Brick and Jenkins Brick requested permission to submit historical results of tests previously conducted at the facilities (Gunning, 2011; Sims, 2011)
, and the EPA granted the request (Telander, 2011a,b)

.
III. Data Compiled and Calculations Conducted from Test Reports
From each test report, the following parameters and emissions data for each test run were compiled into a mas ter run

- by

- run spreadsheet:

• Production rate , in tons per hour (tph)

• Flow rate , in actual cubic feet per minute (acfm)

• Flow rate , in dry standard cubic feet per minute (dscfm)

• Sample v olume , in dry standard cubic feet (dscf)

• Sample v olume , in dry standard cubic meter (dscm)

• Stack m oisture , in percent (%)

• Stack g as t emperature , in degrees Fahrenheit ( ̊F )

• Oxygen content of s tack g as , in percent (%)

• Pollutant concentration , in parts per million (ppm )
, milligrams per dry standard cubic meter ( mg/dscm )
, grains per dry standard cubic foot ( gr/dscf ) , etc.

• Pollutant emission rate , in kilograms per hour (kg/hr )
, pounds per hour ( lb/hr ) , etc.

Once the data were compiled
, the following calculations were conducted in the master

run

- by

- run spreadsheet :

• Converted reporte d concentrations to micrograms per dry standard cubic meter ( μg /dscm )

• Corrected reported concentrations to 7 percen t oxygen ( % O 2 ) using the following equation: 

## ( ) 2 2 

### O % Tested 20.9 13.9 μg/dscm O μg/dscm@7%

− ÷ × =

• Calculated emissions in pounds per ton ( lb/ton ) using emission rate (lb/ hr) and production
rate (tph)3 I V. Q uality A ssurance / Q uality Control Checks

After the test data had been compiled and calculated in the master run

- by

- run spreadsheet, t here were three rounds of QA / QC with BIA and internal QA / QC from RTI and the EPA. Test data determined to be unacceptable after the QA/QC checks were removed from the

run

- by

- run spreadsheet and were not in cluded in the calculation of MACT floor s

. See Appendix A for the list of test data that were removed from the run

- by

- run spreadsheet after the QA/QC checks. See Appendix B for the run

- by

- run test data that were used in the calculation of MACT floors.

A. BIA QA / QC
The BIA provided their first round of comments on a subset of the test data in a memorandum dated June 5
, 2009 (Kuo et al.
, 2009a)

. The BIA retained the services of Mr. Mike Hartman of Air

- Tech Environmental, LLC to review the test reports submitted to the EPA. Mr. Hartman’s review include d comparison of the sampling and analysis approach used in the stack
tests to the appr oach required by the reference method, as well as insights from his experience as a stack tester. The review result s were presented in three groups:

• Tests that BIA believe d should be removed immediately from the EPA’s database used to establish a MACT sta ndard due to documented issues with the test methodology or results.

• Tests that warrant ed additional review due to concerns that proper procedures were not followed, either during the tes ting or the analytical process.

• Tests that appear ed to be incorrectly presented in the EPA’s summary table.

The memorandum from BIA was reviewed with the corresponding test data
, and revisions were made to the test data set

. For acid gas tests where a glass fiber filter was used
, the results were removed from the test data set

. For acid gas tests where the probe and filter temperature were not maintained at the proper temperature per the test method instructions, the results were removed from the test data set . In both of the above cases , the PM data we re retained, as errors in the acid gas testing methodology did not affect the PM results

. The data for any tests that were rejected by the local or state agenc y were also removed from the test data set

. The BIA provided a second round of review on the rem aining test data in a memorandum dated September 4, 2009 (Kuo et al.
, 2009b)

. The purpose of the memorandum was to present the review of the remaining test reports not addressed in the first round of comments , as well as to present BIA’s comments on the EPA’s conclusions regarding BIA’s first memorandum ( Kuo et al. , 2009 a).

The second memo randum from BIA was reviewed with the corresponding test data
, and revisions were made to the test data set

. Similar to the review of the first memorandum, acid gas dat a were removed f or tests where a glass fiber filter was used or where the probe and filter temperature were not maintained at the proper temperature per the test method instructions ( the PM data were retained)

. For PM tests where the testing contractor or laboratory noted a ripped filter, the data were removed from the test data set

. For tests where the testing contractor or laboratory indicated non

- detect values, the data w ere not removed
, but the run was flagged with4 a “<”

. For tests that were run at “ extreme feed type conditions
, ” defined as 100 percent fireclay raw material
, the data were removed as not representative of normal operation

. R esult s for total fluorides measured with EPA Method 13B were not removed from the test data set if they were the only results representative of HF available for that source

. Other revisions included correcting calculation errors or misinterpreted test data that the BIA explained and r evis ing production rates with values BIA provided.
The BIA provided their third round of review in a memorandum dated December 12, 2012 (Kuo and Miller, 2012)

. The purpose of the memorandum was to present specific changes and/or updates to the EPA ’s BSCP MACT f loor r anking d atabase. S everal changes ha d occurred in the BSCP industry since the industry’s section 114 survey submittals, including acquisitions, closures, and new test data. The BIA provided two acquisition updates and a table listing demolished and/or decommissioned kilns

. The BIA also revisit ed a few test reports from t he June 5
, 2009 memorandum (Kuo et al., 2009a) and provided u pdated information regarding facility status, control technology, and emission factors.

The third memo randum from BIA was reviewed with the corresponding test data
, and revisions were made to the inventory and test data set

. The BSCP kiln inventory was updated with the new acquisition
, facility status, and control technology updates ( Holloway , 2014)

. T est data from kilns identified as being demolished and/or decommissioned were remov ed

. A ny applicable data errors identified by the BIA were revised . For tests where the testing contractor or laboratory indicated non

- detect values, the data w ere not removed , but the run was f lag ged with a “<”

. T he source classification for facilities that changed status ( e.g. , major source
, synthetic area source ) was also revised

.
B. In ternal QA / QC

1. Mercury and Non

- Mercury HAP Metal s

In the internal QA/QC of the test data, inconsistencies were found between the Hg and individual non

- Hg HAP m etal values reported in the summary pages of certain test reports and the values reported in the laboratory sections of the test reports. Therefore, the Hg and non

- Hg HAP metal values were reviewed for correctness, starting from the laboratory results. S pecifically, the lab oratory reports were reviewed to extract and compile the mass valu es for five Hg fractions and two non

- Hg HAP metal fractions (see list below)
, the blank fractions, and the

m ethod detection limits (MDLs)
, or other reporting limit if MDL s were not available.

• Front Half (Hg & non

- Hg HAP metal)
, Fraction 1 : Container 1 Filter, Container 2 Acetone Probe Rinse , Container 3 Acid Probe Rinse

• Back Half (Hg & non

- Hg HAP metal) , Fraction 2B : Container 4 H NO 3 / H 2 O 2 (N itric A cid / H ydrogen P eroxide ) Impingers

• Back Half (Hg Only) , Fraction 3A : Container 5A HNO 3

• Back Half (Hg Only) , Fraction 3B : Container 5B KMnO 4 /H 2 SO 4 (Potassium P ermanganate/Sulfuric A cid) A bsorbing Solution

• Back Half (Hg Only) , Fraction 3C : Conta iner 5C HCl Rinse and Dilution5 T he Hg and other HAP metal values were recalculated from the lab oratory data and blank
correct ed when necessary in accord ance with EPA Method 29 guidelines

. The se are the values included in Appendix B for Hg and non

- Hg HAP metals data

.
2. M anganese C ontamination

The 2010 section 114 survey test request included BSCP tunnel kiln Hg testing concurrent with non

- Hg HAP metal testing using EPA Method 29. There is a possibility of the back half fraction (Fraction 2B) for manganese (Mn) being contaminated f rom the permanganate used in Fraction 3B f o r Hg sampling. To check for Mn contamination, the ratio of the back half Mn mass to the front half Mn mass was calculated . If the ratio was over 5, that test run was assumed to ha ve Mn contamination. The test r uns with Mn contamination were removed from the data set

. I f it was determined that only one test run from a particular test for a source w as not contaminated
, the entire test was removed

. The following table indicates the test runs that were removed from the BSCP tunnel kiln data set due to Mn contamination.

Table 1

. BSCP Tunnel Kiln Test Runs Removed Due to M n Contamination

RTI Inventory

- Kiln No

. Test Date Run No. Facility Name City S tate Kiln ID
503 2/8/2011 2 , 3 a Acme Brick Denton TX EPN 21 (Kiln A)

543 9/17/2010 2 Boral Bricks, Inc

. - Augusta Plant 5 Augusta GA EU05

566 9/21/2010 3 Boral Bricks, Inc.

- Salisbury Plant Salisbury NC BK6

547/548 7/13

- 14/2010 1 , 3 a Boral Bricks, Inc.

- Bessemer Plant 6 Bessemer AL 003 & 004 (kiln 1&2)

568 11/17/2010 1 , 3 a Boral Bricks, Inc.

- Union City Plant Union City OK EU02

606 1/18/2011 3 General Shale Brick, Inc. Coosa (Rome) GA Kiln 40 Units K2 (kiln B)
653 1/27/2011 1 Hanson Brick Elgin TX tk

- 2

676 8/17/2010 5 Hanson (formerly Jannock/US Brick) Mineral Wells TX tk

- 2

a Entire test was removed because only one test run from this test was not contaminated.

3. PM C orrection for Test Runs Below 1 mg
As part of the BSCP test data review
, the mass ( mg ) collected for each PM test run was evaluated

. In the EPA memo randum, Data and procedure for handling below detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits
, 1 mg is given as the Representative Detection Level ( RDL ) for PM (Westl in and Merrill
, 2011)

. For test runs with less than 1 mg collected, the 1 mg RDL value was used to calculate the concentration, emission rate, and emission factor for that run. In these cases , the emission factor was calculated as follows:6 hr product ton mg 453.59237 lb 1 hr 1 min 60 min dscf dscf dscm 0.02831685 dscm

mg 1

product ton lb        

× × × ×

=

4. Dioxin s /

Furans

To calculate emiss i ons of total dioxin s /furans, the mass valu es for each of the homologue group totals reported in the laboratory analysis of the test report were summed. The homologue groups are shown in Table 2.

Table 2. Dioxin/Furan Homologue Group Totals Homologue Group Totals Short Hand
Total Tetrachlorodibenzo

- p
- dioxins Total TCDD Total Pentachlorodibenzo

- p
- dioxin Total PeCDD Total Hexachlorodibenzo

- p
- dioxins Total HxCDD
Total Heptachlorodibenzo

- p
- dioxins Total HpCDD Total Octachlorodibenzo

- p
- dioxin Total OCDD Total Tetrachlorodibenzofurans Total TCDF Total Pentachlorodibenzofurans Total PeCDF Total Hexachlorodibenzofurans Total HxCDF
Total Heptachlorodibenzofurans Total HpCDF Total Octachlorodibenzofuran Total OCDF

Next, 17 specific dioxin/furan congeners were considered separately from the homologue group totals. The 17 specific dioxin/furan congener mass values reported in the laboratory analysis of the test report were converted to 2,3,7,8

- TCDD toxic equivalency (TEQ) values for each test run using the 2005 World Health Organization (WHO) toxic ity equivalen c e factors (TEF) (EPA, 2010) in Table 3

. T h e 17 converted TEQ values were then summ ed to calculate a total TEQ value for each run

. Appendix C contains a sample calculation showing how the total dioxin/furan and total TEQ values were calculated from the reported laboratory masses to the final run b y run v alues presented in Appendix B.7 Table 3

. Dioxin/Furan Toxic ity Equivalence Factors

Dioxin/furan congener Short Hand Toxicity equivalence factor 2,3,7,8

- tetrachlorodibenzo

- p
- dioxin 2,3,7,8

- TCDD 1 1,2,3,7,8

- pentachlorodibenzo

- p
- dioxin 1,2,3,7,8

- PeCDD 1 1,2,3,4,7,8

- hexachlorodibenzo

- p
- dioxin 1,2,3,4,7,8

- HxCDD 0.1 1,2,3,7,8,9

- hexachlorodibenzo

- p
- dioxin 1,2,3,6,7,8

- HxCDD 0.1 1,2,3,6,7,8

- hexachlorodibenzo

- p
- dioxin 1,2,3,7,8,9

- HxCDD 0.1 1,2,3,4,6,7,8

- heptachlorodibenzo

- p
- dioxin 1,2,3,4,6,7,8

- HpCDD 0.01 Octachlorodibenzo

- p
- dioxin OCDD 0.0003 2,3,7,8

- tetrachlorodibenzofuran 2,3,7,8

- TCDF 0.1 1,2,3,7,8

- pentachlorodibenzofuran 1,2,3,7,8

- PeCDF 0.03 2,3,4,7,8

- pentachlorodibenzofuran 2,3,4,7,8

- PeCDF 0.3 1,2,3,4,7,8

- hexachlorodibenzofuran 1,2,3,4,7,8

- HxCDF 0.1 1,2,3,6,7,8

- hexachlorodibenzofuran 1,2,3,6,7,8

- HxCDF 0.1 2,3,4,6,7,8

- hexachlorodibenzofuran 2,3,4,6,7,8

- HxCDF 0.1 1,2,3,7,8,9

- hexachlorodibenzofuran 1,2,3,7,8,9

- HxCDF 0.1 1,2,3,4,6,7,8

- heptachlorodibenzofuran 1,2,3,4,6,7,8

- HpCDF 0.01 1,2,3,4,7,8,9

- heptachlorodibenzofuran 1,2,3,4,7,8,9

- HpCDF 0.01 Octachlorodibenzofuran OCDF 0.0003

5. Non

- Detects

As mentioned in S ection I V.B.1
, Hg and non

- Hg HAP metal test runs are comprised of individual fractions. For any test run fraction that had values flagged as being below detection limit (BDL)
, the MDL
, or other reporting limit if an MDL w as not available
, was used as the

mass for that fraction. T he concentrat ion, emission rate, and emission factor for the run were then calculated using the sum of the fractions for each test run

. If all fractions for a run were flagged as BDL, then the run was considered BDL. If there was a mix of fractions flagged as BDL and above detection limit (ADL), then the run was considered detection level limited (DLL). If all fractions for a run were flagged as ADL, then the run was considered ADL.
Similarly
, for dioxin/furan testing
, there are multiple congeners for each TEQ run. T he

run was flagged as BDL if all of the congener masses we re below the MDL; DLL if one or more congeners we re below the MDL; and ADL if all the congeners we re above the MDL. For each fraction/congener mass that is below the MDL, the MDL mass wa s used for the fraction/congener mass and subsequent emissions calculations

. F or m ore information on how these data were treated for purposes of calculating MACT floors, see the memorandum Maximum Achievable Control Technology (MACT) Floor Analysis for Brick and Str uctural Clay Products (Raymond and Sroka , 2014)

.8 6. Production Rates
For most of the test reports, the production rate ( in tph ) w as provided within the test report. Some of the test reports did not provide a production rate. In some of those instances
, the BIA was able to provide the production rate. A lternatively, if a nother test was conducted on the same source in a similar time frame, the production rate for that test was used. As a last
resort , i f the production rate used during the test was not p rovided in the test report or survey response, and it was not available from the facility, the production rate was set equal to 83 percent of the kiln capacity

. The 83 percent capacity utilization was a conservative estimated developed from the available production data and design capacities reported in the BIA survey data (Schimmel, 2008)

.
7. Kiln C onfigurations

In some cases, multiple kilns are ducted together to the outlet stack being tested. Each kiln operating during the time of testing was assumed to have the same concentration and emission factor value. Their emission rate values were calculated as a proportion of the outlet stack value , based on a ratio of production rates

. If any of the kilns were not operating during the test
, the emission values do not apply to those kilns.

V. References
EPA (U.S. Environmental Protection Agency). 2010. Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8

- Tetrachlorodibenzo

- p

- dioxin and Dioxin

- Like Compoun ds

. Publication No. EPA/100/R

– 10/005. Available at: http://www.epa.gov/raf/files/tefs

- for

- dioxin

- epa

- 00

- r

- 10

- 005

- final.pdf . December 2010.
Gunning, G. 2011. “ Request for exemption from testing requirements of section 114 information collection request for Interstate Brick. ” Letter and attachment from Gerry Gunning, Interstate Brick, to J eff Telander, U

. S

. E nvironmental Protection Agency. January 4, 2011.
Holloway, K. 2014. Updated BSCP Inventory Database and Documentation

. Memorandum from Thomas Holloway, RTI International , to Jeff Telander, EPA/OAQPS/SPPD

. November 6, 2014

. Johnson, S. 2013. Source test report review

– General Shale Brick, Inc, Mooresville, IN, Feb. 1, 2012 . Memorandum from Steffan Johnson, EPA/SPPD, to Jeff Telander, EPA/SPPD

. August 9, 2013.

Kuo, I.
, Miller, S., and Hartman, M. 2009a. Preliminary review of test reports

. Memorandum from Irene Kuo and Susan Miller, Brick Industry Associat ion, and Michael Hartman, Air

Tech Environmental, LLC, to Jeff Telander, EPA/SPPD . June 5, 2009.

Kuo, I.
, Miller, S., and Hartman, M. 2009b. Subsequent review of test reports and BIA comments on EPA actions on preliminary review of test reports

. Memora ndum from Irene Kuo and Susan Miller, Brick Industry Association, and Michael Hartman, Air

- Tech Environmental, LLC, to Jeff Telander, EPA/SPPD . September 4, 2009.9 Kuo, I. and Mille r, S . 2012. Review of EPA BSCP MACT Floor Ranking Database (Version dated 3/15/2010)

. Memorandum from Irene Kuo and Susan Miller, Brick Industry Association, to Jeff Telander, EPA/SPPD . December 12, 2012.
Raymond, G. and Sroka, K. 2014. Maximum Achievable Control Technology (MACT) Floor Analysis for the Brick and Structural Clay Products Proposed Rule

. Memorandum from Gabrielle Raymond and Kristin Sroka, RTI International, to Jeff Telander, EPA/OAQPS/SPPD

. November 6, 2014.

Schimmel, T . 2008. “ Brick Industry As sociation MACT data collection. ” E

- mail and attachments from Terry S chimmel, Brick Industry Association
, to Jeff T elander, U.S. Environmental Protection Agency

. October 17, 2008.

Sims, B. 2011. “ Request for exemption from testing requirements of section 114 information collection request for Jenkins Brick and Tile Co. ” Letter from Brian Sims, Jenkins Brick and Tile Co., to J eff Telander, U

. S . Environmental Protection Agency

. January 13, 2011.

Telander, J. 2011 a

. “ EPA approval of request for exemption from testing requirements of section 114 information collectio n request for Interstate Brick. ” E

- mail from Jeff Telander, U.S. Environmental Pro tection Agency, to Gerald Gunning, Interstate Brick. January 12, 2011.

Telander, J. 2011 b

. “ EPA approval of request for exemption from testing requirements of section 114 information collection request for Jenkins Brick and Tile Co. ” E

- mail from Jeff Telander, U.S. Environmental Protection Agency, to Brian Sims, Jenkins Brick and Tile Co. February 15, 2011.
Tsirigotis, P. 2008. “ Section 114 information collection request to selected brick and structural clay products facilities. ” Letter a nd attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Terry Schimmel, Boral Bricks, Inc., transmitting section 114 information collection request asking for information on brick and structural clay products processes, emissions, an d controls. Identical letters sent to other addressees listed ( The Belden Brick Co., Boral Bricks, Inc., Carolina Ceramics Brick Co., General Shale Brick, Inc., Glen

- Gery Corp., Hanson Building Products America, Morin Brick Co., and Taylor Clay Products, Inc. )

. June 4, 2008.
Tsirigotis, P. 2010a. “ Section 114 information collection request to The Belden Brick Co. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to William Belden, Jr., The Belden Brick Co., transmitti ng section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. June 11, 2010.
Tsirigotis, P. 2010b. “ Section 114 information collection request to Boral Bricks, Inc. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Terry Schimmel, Boral Bricks Inc., transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for s pecified emission points. June 11, 2010.10 Tsirigotis, P. 2010c. “ Section 114 information collection request to Hanson Building Products America. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to J. David McKeown, Ha nson Building Products America, transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. June 11, 2010.
Tsirigotis, P. 2010d. “ Section 114 information collection request to Acme Brick Co. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Dennis Knautz, Acme Brick Co., transmitting section 114 information collection request asking for information on startup and shutd own events and emission data for specified emission points. November 17, 2010.
Tsirigotis, P. 2010e. “ Section 114 information collection request to General Shale Brick, Inc. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection A gency, to Dave McNees, General Shale Brick, Inc., transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. November 17, 2010.
Tsirigotis, P. 2010f. “ Se ction 114 information collection request to Glen

- Gery Corp. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Steve Matsick, Glen

- Gery Corp., transmitting section 114 information collection request asking for informat ion on startup and shutdown events and emission data for specified emission points. November 17, 2010.
Tsirigotis, P. 2010g. “ Section 114 information collection request to Interstate Brick. ” Letter and attachments from Peter Tsirigotis, U.S. Environmen tal Protection Agency, to Gerry Gunning, Interstate Brick, transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. November 17, 2010.
Tsirigotis, P. 20 10h. “ Section 114 information collection request to Jenkins Brick and Tile Co. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Mike Jenkins, Jenkins Brick and Tile Co., transmitting section 114 information collecti on request asking for information on startup and shutdown events and emission data for specified emission points. November 17, 2010.
Tsirigotis, P. 2010i. “ Section 114 information collection request to Taylor Clay Products, Inc. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Charles Taylor, Taylor Clay Products, Inc., transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emiss ion points. November 17, 2010.

Westlin, P. and Merrill, R. 2011. Data and procedure for handling below detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits

. Memorandum from Peter Westlin, SPPD/MPG and Raymond Merrill, AQAD/MTG, to SPPD management and MACT rule writers. December 13, 2011.Appendix A

Test Data N ot U sedA

- 1 Table A

- 1

. Tunnel Kiln Test Data Removed from Database after QA/QC, Not Used in MACT Floor Analyses Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded

ACME

- 5 Acme Brick Company Denton TX 2/8/2011 2010 survey 503 Removed Non

- Hg HAP Metal results due to only one test run from this test was not Mn contaminated

ACME

- 15 Acme Brick Company McQueeney TX 10/14/2003 2008 survey Located at t rue ar ea s ource facility

ACME

- 16 Acme Brick Company Oklahoma City OK 3/15/2002 2008 survey Located at t rue ar ea s ource facility

BELD

- 1 Belden Brick Company Sugarcreek Plant 3 OH 7/25/2011 2010 survey 527 Rejected by O hio EPA

BELD

- 1 Belden Brick Company Sugarcreek Plant 6 OH 5/30/2007 2008 survey 528, 529, 530 Rejected by O hio EPA

BELD

- 1 Belden Brick Company Sugarcreek Plant 8 OH 5/3/2001 2008 survey 532 Test conducted prior to curr ent control device installation

BELD

- 1 Belden Brick Company Sugarcreek Plant 8 OH 8/26/2003 2008 survey 531, 532, 533 Rejected by O hio EPA

BELD

- 1 Belden Brick Company Sugarcreek Plant 8 OH 1/20/2006 2008 survey 531, 532, 533 No HAP data; o nly SO 2 data

BELD

- 1 Belden Brick Company Sugarcreek Plant 9 OH 5/31/2007 2008 survey 534, 535 Rejected by O hio EPA

BORA

- 1 Boral Bricks Inc. Smyrna GA 11/2/2004 2008 survey 537, 538 Test conducted prior to current control device installation

BORA

- 1 Boral Bricks Inc. Smyrna GA 2/8/2005 2008 survey 537, 538 Test conducted prior to curr ent control device installation

BORA

- 1 Boral Bricks Inc. Smyrna GA 10/17/2006 2008 survey 537, 538 Removed PM results due to ripped filter

BORA

- 1 Boral Bricks Inc. Smyrna GA 3/28/2007 2008 survey 538 Removed PM Run 2 results due to ripped filter

BORA

- 3 Boral Bricks Inc. Augusta Plant 6 GA 9/10/1991 Docket A

99

- 30 542 Kiln demolished and/or decommissioned

BORA

- 3 Boral Bricks Inc. Augusta Plant 5 GA 9/14/2010 2010 Survey 543 Removed Non

- Hg HAP Metal Run 2 results due to Mn contamination

BORA

- 5 Boral Bricks Inc. Bessemer AL 5/15/2007 2008 survey 547, 548 Remove d HF and HCl results due to low probe and filter temperatures ; r etain ed PM results

BORA

- 5 Boral Bricks Inc. Bessemer AL 7/13

- 14/2010 20 10 survey 547, 548 Removed Non

- Hg HAP Metal results due to only one test run from this test was not Mn contaminatedA

- 2 Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded

BORA

- 9 Boral Bricks Inc. Lexington SC 1/23/1997 Docket A

99

- 30 553 Kiln demolished and/or decommissioned

BORA

- 11 Boral Bricks Inc. Macon MS 4/22/1999 2008 survey 555 Kiln demolished and/or decommissioned

BORA

- 12 Boral Bricks Inc. Marshall TX 6/1/1986 Docket A

99

- 30 557 Kiln demolished and/or decommissioned

BORA

- 12 Boral Bricks Inc. Marshall TX 3/12/2002 2008 survey 557 Kiln demolished and/or decommissioned

BORA

- 13 Boral Bricks Inc. Muskogee OK 12/13/2005 2008 survey 558 Test conducted prior to curr ent control device installation

BORA

- 13 Boral Bricks Inc. Muskogee OK 2/7/2006 2008 survey 558 Test conducted prior to current contr ol device installation

BORA

- 17 Boral Bricks Inc. Salisbury NC 9/8/2005 2008 survey 565 Kiln demolished and/or decommissioned

BORA

- 17 Boral Bricks Inc. Salisbury NC 9/21/2010 2010 survey 566 Remove d Cl 2 Run 1 results as outlier

BORA

- 17 Boral Bricks Inc. Salisbury NC 9/21/2010 2010 survey 566 Removed Non

- Hg HAP Metal Run 3 results due to Mn contamination

BORA

- 19 Boral Bricks Inc. Union City OK 5/25/2006 2008 survey 568 Remove d HF and HCl results due to low probe and filter temperatures ; r etain ed PM results

BORA

- 19 Boral Bricks Inc. Union City OK 3/14/2007 2008 survey 568 Remove d HCl results due to low probe and filter temperatures

BORA

- 19 Boral Bricks Inc. Union City OK 11/17/2010 20 10 survey 568 Removed Non

- Hg HAP Metal Run 3 results due to Mn contamination

BORA

- 20 Boral Bricks Inc. Corona CA 12/2/1999 2008 survey Located at t rue ar ea s ource facility

BORA

- 21 Boral Bricks Inc. Van Wyck SC 5/14/1997 Docket A

99

- 30 569, 570 Kiln demolished and/or decommissioned

BIA

- 120 Bowerston Shale Co Bowerston OH 9/27/2007 BIA 571 Run 1 HF results excluded by O hio EPA

GENE

- 2 General Shale Brick, Inc

. Johnson City TN 7/27/1993 2008 survey 601 Kiln demolished and/or decommissionedA

- 3 Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded

GENE

- 4 General Shale Brick, Inc

. Fairsdale KY 9/21/2001 2008 survey 603 Remove d HF results due to glass fiber filter ; r etain ed PM results

GENE

- 4 General Shale Brick, Inc

. Fairsdale KY 12/18/2001 2008 survey 603 No HAP data; o nly SO 2 data

GENE

- 4 General Shale Brick, Inc

. Fairsdale KY 12/15/2005 2008 survey 604 Remove d HF and HCl results due to glass f iber filter; retained PM results

GENE

- 5 General Shale Brick, Inc

. Coosa GA 3/17/2005 2008 survey 606 No HAP data; o nly SO 2 data

GENE

- 5 General Shale Brick, Inc

. Coosa GA 1/18/2011 20 10 survey 606 Removed Non

- Hg HAP Metal Run 3 results due to Mn contamination

GENE

- 5 General Shale Brick, Inc

. Coosa GA 6/24/2008 2008 survey 605 No HAP data; o nly SO 2 data

GENE

- 5 General Shale Brick, Inc

. Coosa GA 1/18/2011 2010 survey 606 Remove d HF results, kiln retested 7/11/11

GENE

- 7 General Shale Brick, Inc

. Mooresville IN 11/2/2006 2008 survey 609 Kiln demolished and/or decommissioned

GENE

- 7 General Shale Brick, Inc

. Mooresville IN 11/3/2006 2008 survey 610 Remove d HF and HCl results due to low probe and filter temperatures ; r etain ed PM results

GENE

- 7 General Shale Brick, Inc

. Mooresville IN 2/1/2012 2010 survey 611 Discard ed entire test report per Stef fan Johnson
, EPA (Johnson, 2013)

GENE

- 8 General Shale Brick, Inc

. Blue Ridge (Roanoke) VA 2/23/2005 2008 survey 612, 613 Remove d HF Run 1 results due to low probe and filter temperatures ; r etain ed other acid gas and PM results

GLEN

- 2 Glen Gery Caledonia OH 5/1/2007 2008 survey 639, 638 No HAP data; o nly SO 2 dataA

- 4 Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded

GLEN

- 6 Glen Gery Summerville PA 4/26/2005 2008 survey 643 Remove d HCl results due to questionable mass collection

HANS5 Hanson Brick East, LLC Elgin TX 1/27/2011 2010 survey 653 Removed Non

- Hg HAP Metal Run 1 results due to Mn contamination

HANS6 Hanson Brick East, LLC Corunna MI 6/7/1995 Docket A

99

- 30 655 Remove d fluorides results, use d 2010 HF data

HANS10 Hanson Brick East, LLC Pleasant Garden NC 5/10/2006 2008 survey 666 Kiln demolished and/or decommissioned

HANS12 Hanson Brick East, LLC Stanton KY 12/1/2004 2008 survey 670 Kiln demolished and/or decommissioned

HANS15 Hanson Brick East, LLC Mineral Wells TX 8/17/2010 2010 survey 676 Removed Non

- Hg HAP Metal Run 5 results due to Mn contamination

8 ( BIA

- 099 ) Redland

Rocky Ridge Plant Rocky Ridge MD 8/5/1998 BIA 741 Incomplete test report , no run by run data available

66 ( BIA

- 015 ) Redland

Harmar Plant Cheswick PA 3/5/2002 BIA 738 Remove d HF, HCl, PM results due to " e xtreme f eed" issue
66 ( BIA

- 015 ) Redland

Harmar Plant Cheswick PA 3/11/2002 BIA 738 Remove d HF and HCl results due to low probe and filter temperatures ; r etain ed PM results
66 ( BIA

- 015 ) Redland

Harmar Plant Cheswick PA 4/22/2005 BIA 738 Remove d HF and HCl results due to low probe and filter temperatures ; r etain ed PM results

66 ( BIA

- 015 ) Redland

Harmar Plant Cheswick PA 10/26/2006 BIA 738 Remove d HF and HCl results due to low probe and filter temperatures ; r emove d HF, HCl, PM results due to

" e xtreme f eed" issue

141 ( BIA

- 114 ) Stark Ceramics, Inc

. East Canton OH 9/16/1993 Docket A

99

- 30 752 Kiln demolished and/or decommissioned

149 ( BIA

- 014 ) Redland

Cushwa Plant Williamsport MD 5/10/2006 BIA 736 Remove d HF and HCl results due to low probe and filter temperatures ; r etain ed PM results

BIA

- 183 Vermont Brick Mfg, LP Highgate VT 10/1

- 3/2002 Facility Located at t rue ar ea s ource facility

BIA

- 206 Pine Hall Brick Co Inc

. Fairmount GA 6/22/2005 BIA 725 Remove d HF and HCl results due to glass fiber filter ; r etain ed PM results

BIA

- 206 Pine Hall Brick Co Inc

. Fairmont GA 2/3/2004 BIA 724 Remove d HF and HCl results due to glass fiber filter ; r etain ed PM resultsAppendix B

Final R un - by

- R un ValuesB

- 1 The final run

- by

- run values for HF, HCl, Cl 2 , PM, Hg, individual non

- Hg metal HAP
, and dioxin/furan runs for tunnel kilns and dioxin/furan runs for dryers are provided in the corresponding Appendix B Microsoft Excel® file. The file include s the parameters and emission data compiled from each test report and the calculations conducted on the data.Appendix C

Dioxin/Furan and TEQ Sample CalculationsC

- 1 A sample calculation of run by run reported laboratory masses converted into final total dioxin/furan and total TEQ run

- by

- run values is provided in the corresponding Appendix C Microsoft Excel® file.